Policy for the Audit Frequency of a Given Licence or Licensee
This policy describes the minimum length of time between Board compliance audits for a specific licence and ensures one licensee will not be subject to more than one Board compliance audit in a single year.
The Forest Practices Board serves the public interest as the independent watchdog for sound forest practices in British Columbia. A key function of the Board is to conduct periodic independent audits of forest practice performance of both government and industry in the province, and to report the findings of these audits to the public and the three ministers responsible for implementing the Forest and Range Practices Act (FRPA), previously the Forest Practices Code of British Columbia Act (the Code).
II. Compliance audit selection – a random process
To ensure that compliance audits are undertaken without bias, the Forest Practices Board randomly selects auditees, such as a licence holder or BC Timber Sales business area. Auditees are not selected on the basis of location or level of performance. Auditees may also be selected as part of an area-based thematic audit on a defined land base. This defined land base is selected randomly, and is not based on location or level of licensee performance.
Over the past eight years, the Board has periodically reviewed the issue of withdrawing a licence for a fair and reasonable length of time from the 'pool' for audit selection, once it has been the subject of a Board compliance audit. Each of these reviews has concluded that the term of three years seemed appropriate for the withdrawal of a licence. Although there is no written Board policy regarding the length of time a licence is withdrawn from the pool, this three-year timeframe has been communicated publicly on several occasions.
With the three-year term for a licence to be out of the pool for audit selection, and given the random nature of audit selection, it is possible that a licence could be audited once every four years. Under current Board procedures, it is also possible that a licensee who holds many licences could be audited one or more times every year.
III. Audit frequency – how long a licence or licensee should be withdrawn from the pool for audit selection
The Board has concluded that the length of time that a licence should be withdrawn from the pool for audit selection needed to be revised in order to facilitate the dispersion of compliance audits across all licences so that more licences are audited through the random audit selection process.
To that end, the Board’s updated policy concerning audit frequency for a given licence is to extend the ‘out-of-pool’ time from three years to five years. This policy will be applied beginning in the 2004 audit season.
By extending the ‘out-of-pool’ time to five years, the licence would be ensured a longer period between Board audits. This ensures the Board is not re-auditing a licence too quickly, especially given the fact that there are so many other licences that have not yet been audited.
In addition to extending the ‘out-of-pool’ time to five years, the Board has also revised its policy relating to licensees. In the past it was possible that a licensee could have two or more licences randomly selected for a Board audit the same year. As of the 2004 audit season, the Board will ensure that once a licensee has a licence selected for audit in a given year, that licensee will not be eligible to have any other licences selected for audit in the same year. This will ensure that the Board reaches as many different licensees as possible in any given year.
It should be noted, however, that ensuring that one licensee isn’t subject to a compliance audit more than once in a year does not preclude that same licensee from being selected as an auditee as part of an area-based thematic or topical audit in that same year.
As well, all licensee activities are subject to examination by the Board as part of a public complaint investigation or special investigation at any time, regardless of audit frequency.
It is the Board’s hope that these new policies will ensure that the Board’s audit program is being applied fairly to all licensees and will provide the public with a broader picture of performance on the hundreds of forest licences in British Columbia.